Hillary Clinton made sweeping promises about transparency at her family’s foundation before she was confirmed in 2009 as President Obama’s secretary of State.

At the time, Clinton was under pressure from senators in both parties and even the White House to agree to be transparent given the potential for ethical concerns with the Clinton Foundation, which has accepted donations or entered into charitable partnerships with foreign and corporate interests.

During her confirmation hearing, the Clinton Foundation was mentioned 62 times as senators worried that foreign governments could use donations to the foundation to curry favor with the Clinton State Department. Clinton said at the hearing that “all contributors will be disclosed,” and pointed to a memorandum of understanding co-signed in December 2008 between the foundation and the transition team of then president-elect Barack Obama that pledged unprecedented transparency into her family’s sprawling organization.

Some of Clinton’s transparency promises ended up not being kept.

The failures were sometimes complicated – in one example a foreign country’s laws hampered the foundation’s ability to reveal names of donors. Nonetheless, these controversies are now returning to haunt Clinton as November’s election draws near.

Here are seven ways in which the foundation fell short on its transparency pledges.

The office of then president-elect Obama was sufficiently worried about the Clinton Foundation’s continued acceptance of foreign donations that on December 16, 2008, prior to Clinton’s confirmation hearings, it co-signed a memorandum of understanding in which the foundation agreed to a number of transparency measures.

The document – signed by top Obama adviser Valerie Jarrett and Bruce Lindsey, the then-CEO of the Clinton Foundation – promised that any new foreign donations into the foundation or the material increase of existing foreign donors would be disclosed during Clinton’s tenure as secretary of State.

As Reuters revealed last year, officials at the Clinton Health Access Initiative (CHAI) — an HIV/AIDs-focused non-profit that falls under the Clinton Foundation’s umbrella — admitted they failed to uphold these commitments during Clinton’s entire tenure, from 2009 to 2013.

“Not doing so was an oversight which we made up for this year,” said CHAI spokeswoman Maura Daley in a statement to Reuters.

Asked by The Hill to explain these transparency failures in more detail, the Clinton Foundation did not respond.

Another Clinton Foundation promise designed to reassure the Obama administration was a pledge that prospective foreign donations would be submitted to State Department ethics officials for review.

The relevant section of the signed memorandum reads: “Should an existing contributing country elect to increase materially its commitment, or should a new contributor country elect to support CHAI, the Foundation will share such countries and the circumstances of the anticipated contribution with the State Department designated agency ethics official for review, and as appropriate, the State Department’s designated agency ethics official will submit the matter for review by a designated official in the White House Counsel’s Office.”